Safety Programming

Safety programming is establishing the priority and following order of the safety action steps that must be taken to reach the safety objective. If the objective is to 

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The beam from a laser can inflict damage on various parts of the human body. In addition, there are other ha2ards associated with the use of lasers. Therefore, a weU-conceived and well-organised safety program is required for the use of lasers, particularly those of high power. 

E. M. Bergtraun, "Organising An Effective FacUity Safety Program," MIPE Facilities, July/Aug. 1990. 

Center for Chemical Process Safety. In 1985, the American Institute of Chemical Engineers estabHshed the Center for Chemical Process Safety (CCPS) (New York). The objective of the CCPS was to help prevent catastrophic chemical accidents by compiling information on the latest scientific and engineering practices, safety programs, and adininistrative procedures of the larger members of the chemical industry, so that they can be shared with other (and particularly the smaller) members of the chemical and petrochemical industries. 

Government regulations reqmre hazard and risk analysis as part of process safety management (PSM) programs. These are part of the process safety programs of many chemical process facilities. 

API RP 2221, Manager s Guide to Implementing a Contractor Safety Program, 1st ed., June 1996... 

Does the company have a written health and safety program ... 

Automobile and marine fuel handling is covered in NFPA 30A. This section addresses specific operations in which static electricity has caused fires and injury. Relevance to the CPI includes employee safety programs and company-owned gasoline fueling depots. 

For these reasons, the inherently safer approach should be an essential aspect of any safety program. If the hazards can be eliminated or reduced, the extensive layers of protection to control those hazards will not be required. 

A primary objective of any safety program is to maintain or reduce the level of risk in the process. The design basis, especially inherently safer features that are built into the installation, must be documented. Management of change programs must preserve and keep the base record current and protect against elimination of inherently safer features. For identical substitution, the level of risk in the process is... 

The DOE and private industry have learned many lessons from years of experienee in site remediation. This book will refer to seleeted lessons learned from the DOE, the Army Corps of Engineers, private industry, and personal experienee. After reading this book the reader should have a better understanding of how to interpret the hazardous waste requirements to make sure eomplianee is maintained at a high level for eaeh site-speeifie aetivity. Over and above eomplianee, the authors eneourage the development of health and safety programs to help build a sound and workable safety eulture that ean be utilized aeross all boundaries. 

Provide some methods to help promote eonsisteney in health and safety program development for handling hazardous materials... 

Training is the heart of any safety program, espeeially when the work involves hazardous substanees and other related issues. Training is intended to enable the workers to reeognize health and safety hazards, and to prevent ineidents. As a result, training inereases produetivity and in some eases ean improve worker morale [4]. 

This same organization may insist on fall proteetion at five feet instead of the six feet rule as outlined in the eonstruetion standard 29 CLR 1926.503, and so on. The point is simple. If you follow OSHA you have set minimum requirements for your operation. This is okay for some situations, but progressive organizations will set higher standards to make sure that all employees are proteeted to a greater extent. It is your deeision, and a refleetion of your eompany s safety program. 

Non-RCRA-permitted TSDs and waste treatment activities not covered by RCRA (e.g., wastewater treatment facilities permitted under the Clean Water Act) are not covered by HAZWOPER, except for emergency response and some limited waste management operations. Specific HAZWOPER elements are assimilated into the existing health and safety program based on hazard analyses. Worker protection requirements are met through existing health and safety plans [1]. 

Key documents that are developed during the planning stages can be used to focus and direct the compliance strategy, to outline the health and safety program/plan requirements, and to establish work controls. These documents are usually developed after contract award and before mobilization. 

Lessons learned provide valuable information for managing health and safety programs. This information addresses conditions to be avoided or recommended practices. Lessons learned typically have the potential for wide-ranging application. Effective identification of lessons learned requires an awareness of emerging practices, programs, and technologies related to hazardous waste activities [3]. 

There are at least a couple of conclusions we should draw from this example. If you are going to use safety alerts, even though your intentions are honorable, you may offend the injured party, the folks who took part in the investigation, and others. Be prepared for the fall-out. Also, keep in mind that you need to talk the talk and walk the walk. If an incident occurs and a corrective action is indicated, it behooves you to implement some level of corrective action. If you do not implement a sound corrective action, your company likely has an ineffective safety program to go along with a variety of outstanding lawsuits. 

Exactly what type of lessons are learned cannot be foreseen. The size and diversity of site activities give rise to a wide variety of health and safety hazards. Individual sites need to document and disseminate information that could enhance their hazard recognition and mitigation. Effective documentation is an important concept that everyone needs to buy in to if the safety program is going to be effective. Wliy workers fail to document potential problems has been the subject of much debate. 

A properly designed and implemented site-speeifie HASP provides the basis for proteetion of workers, visitors, and the publie. The HASP is a requirement at all HAZWOPER sites [1] and will likely soon beeome a requirement at all sites. However, before we begin development of the HASP there is a lot of work to do. The following diseussion will outline the diflferenees between a health and safety program and a HASP doeument. 

The HASP, on the other hand, foeuses on the site-speeifie aetivities and outlines the appropriate elements of the site s existing health and safety program to the related task. The existing programs are reviewed to identify those elements meeting the needs of the planned site aetivity. Program elements and proeedures are supplemented with worksite-speeifie detail and tailored to meet speeial or unique aspeets of the hazardous waste aetivity on an as-needed basis [1]. 

Adequate resources are fundamental to any project, but even more so to a well-functioning health and safety program. Many mishaps have been traced to improperly trained workers, lack of adequate tools and equipment, or requirements for personnel to work excessive hours or at unfamiliar jobs because of inadequate staffing or lack of adequate resources. The multidisciplinary team approach can help to identify required resources and can help balance, identify, and coordinate necessary assets. 

Wlien a worksite includes both radiological and nonradiological hazards, the HASP should address both hazards. A site-specific HASP can supplement health and safety programs by providing site-specific and pertinent information, requirements, and strategies for each task. 

A properly written HASP should contain worker health and safety program information, guidance, and alternatives. The HASP should quickly answer the following questions What hazards are present and How can we make sure that the tasks will be performed safely The following general guidelines will help to answer these questions ... 

Not all existing procedures or program elements of the overall health and safety program need to be incorporated into the HASP. For example, if noise is a hazard, the plan does not have to cite the entire hearing conservation program. Procedures already established elsewhere may be referenced, as applicable. In another example, if a confined-space-entry procedure is required, the HASP could reference the particular procedure which is part of the overall program. The next step would be to identify confined spaces at the worksite where the procedure applies, and then provide appropriate implementation procedures (e.g., conditions to be monitored, evaluation of the space, issuance of an entry permit). If special operational procedures apply to the worksite, they can be attached to the HASP using an appendix. 

The HASP builds on and enhanees existing health and safety program eomponents. In deseribing PPE, generie deseriptions of Levels A, B, C, and D should be avoided. Instead, define eaeh level for the spe-eifie area or aetivity in question. Typieal questions eoneerning HASP development are summarized in the following seetions [1]. 

Although inspeeting the worksite is important for enforeement of important requirements, it is also a useful tool to help determine if the site orientation, the safety plan, or the safety program is eflfeetive. If newly oriented workers are out of eomplianee in eertain areas, this may indi-eate that the orientation needs to be reviewed and improved. 

Ensure that the contractor/subcontractor can implement a comprehensive health and safety program in compliance with applicable regulations, including accident prevention programs, medical surveillance, training, work practice controls, use of personal protective equipment, and so on. 

A written safety program and job-specific safety plan... 

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